The Honorable Nicholas G. Garaufis
United States District Judge
United States District Court
225 Cadman Plaza East
Brooklyn, New York 11201
Re: United States v. Keith Raniere, et al., 18 Cr. 204 (NGG)

Dear Judge Garaufis:

We write to supplement our Third Motion for Bond (Dkt. 303) and reply to the Government’s short letter in response to the Motion (Dkt. 304).

We write to alert the Court to Raniere’s detention at the MDC, which is functioning as a more extreme deprivation of his rights than what is typical for pretrial detainees. During the Government shutdown, legal visiting was constantly suspended, making pretrial and trial preparation extremely difficult. [1]

When the Government reopened, legal visiting resumed and we did not include this to our Motion for Bond (Dkt. 303) because regular visiting would apparently have resumed. However, now, even after the temporary resolution of the shutdown, we have been prevented from visiting Raniere because the
MDC has been closed all week.

MDC has been without heat, electricity, hot water, commissary or warm food since January 27, 2019, following an apparent fire in the institution. Raniere has relayed to us, through a colleague in the Federal Defender’s Office, that MDC has not provided Raniere with any means to keep warm—and apparently the temperature in the institution is 44 degrees. Raniere has also informed us that the corrections officers are wearing masks to mask the smell of noxious fumes, but have not provided any masks to the inmates.

These conditions have substantially hindered trial preparation. Counsel has been unable to follow up Monday’s proceedings and issues raised during that appearance, review multiple recent filings, and prepare Raniere for the February 6 court appearance and issues to be addressed at the conference.

Counsel has called MDC daily asking when we can next expect to be able to see Raniere and they have been unable to answer us. Even in the frigid temperatures during the Polar Vortex this week, counsel Danielle Smith traveled to the MDC from Albany, NY to see visit our client and assess the situation in person. The guards would not let her in.

These conditions merit relief. Not only is Raniere in MDC with no heat or hot water in the coldest temperatures in the United States to date this year, but he is also unable to meet with counsel to prepare for his imminent trial. In a case that the Government requested be deemed
complex, [2] with a significant volume of discovery, it will be nearly impossible to prepare for trial
with Raniere detained.

The lack of counsels’ access to our client represent a violation of his Due Process rights as set forth in our bail application and his Right to the effective assistance of counsel.

Often without advance notice, legal visiting at the MDC was suspended on January 4, 5, 6, 9, 10,
11, 14 and 21.

Footnote 2

The Government notes that “defendant calls the government’s request to designate the case
complex a ‘ruse,’ despite this Court’s finding of complexity (DE 138) and the defendant’s
affirmative consent to the complex case designation at every court appearance since the finding
was made.” (Dkt. 304 at 1 at n.1.) Raniere notes, as he has since the Government first sought to
designate this case complex in September, that the complex nature of it “is a problem of the
government’s own making.” (September 12, 2018 Ltr .on Behalf of All Defendants at 3.) Counsel
stated then, and has stated since that “the government has frustrated defense counsel at every turn
in our efforts to make this case manageable.” (Id.)

If the description of those conditions is accurate, I think its appalling to treat the prisoners this way.
I think all of us who have suffered because of crime can feel vengeful at times and hope that the criminals suffer, but treating them this way doesnt help anyone, and their suffering doesn’t help their victims heal.

I agree the treatment is appalling, especially since many there are simply awaiting trial and have not yet been convicted. Some of them may even be innocent. Reading the NY Times coverage was eye opening.

It’s not a country club, but for God’s sake, if the heat breaks and it’s 44 degrees or lower in there, what would it take to obtain and hand out some blankets?

Now that is funny. It could take his mind off the Non-club Med Cancun conditions he feel entitled to. A good branding could also toughen up the stumpy soft cry baby Jane. It’s character building, right.

Perhaps Keith Raniere in a former life was a holocaust survivor and is just having flashbacks? Keith believes many of us our reincarnated. Reincarnation can be a tricky thing poor Kieth.
Or more likely my impromptu article published on January 26, 2019 inspired the Great Vanguard and his criminal defense attorney.
I can only dream to have influenced the worlds greatest mind Vanguard!!!

Actually it would be a nightmare. I would never want to help out an alleged child molester.

Who does he think he is?! This is prison for crying out loud! There are a lot of other prisoners in there and we don’t hear then whining. Maybe he should consider sharing his bed with another inmate to “warm up.” LOL

In the immortal words of Vanguard: “There are NO VICTIMS only volunteers.”

At least two of these incidents were mere manifestations of Vanguard’s own mighty Mothman powers — the January 27th fire and the Polar Vortex itself, obviously.

But the most chilling revelation of KAR’s powers in this seemingly frivolous filing is found in its footnotes, wherein the Govt.’s “RUSE” is revealed. For it was KAR — The Vangurd himself —not the evil Govt. oppressors — who first declared this case complex, as God and Marc Agnifilo both witnessed!

KAR lawyer Marc Agnifilo is just eating up the legal defense trust fund while there is still some pay dirt left. He knows the trial isn’t going to happen in April. If Marc is such a Super Lawyer, he will have plenty of time to meet with his client and come up with a bag of lies in an attempt to get a jury to buy them. They won’t and Marc and KAR are going to lose.

Raniere time after time continues to prove that he himself cannot apply his technology making it CRAP and his life is now just CRAP. If he could, the conditions at the MDC would not be any issue for him. Sure it’s no Club Med Cancun, it’s jail. You put yourself there KAR, get over yourself.

Corrections officers wearing masks to mask the smell of noxious fumes are most likely coming for KAR himself. The man hates to shower.

This is a little off topic, but I stumbled upon this KAR quote in his affidavit in the Rick Ross case. He makes this statement after various states sued the crap out of him over Consumers Buyline.

“Throughout this process I had learned how people can cheat and win. In mathematical game theory cheaters, if undetected, always have the advantage because they have more options. I now added game theoretic strategies to my model. This enabled an ethical honest person to choose the best outcome options against a potentially dishonest opponent. Sadly, I found, we live in a world that has more than just opinion-based honest conflicts. We live in a world where some people cheat and cheaters have advantages.”

So…was this the genesis of his aggressive litigation tactics? To “choose the best outcome against a potentially dishonest opponent” (as an “ethical honest person”)? I’m beginning to think this man could convince even himself of anything, no matter how absurd.

He now sits in uncomfortable confinement as a result of his own misguided tactics. If he had had any sense, he would have calculated his moves so that he would now be on home confinement instead of in pretrial detention.

I taught my children many many things as they were growing up. One of the important life rules is to “follow the laws of the land”. Don’t get yourself mixed up in illigal shit, because if you do. you will end up in a Pen, a real human pigpen.
Mr Raniere is being accused of sexually abusing and enslaving innocent children and not so innocent grown ass WEAK women.
He is were he put himself. He got himself mixed up in iilegal things.
No need to feel sorry for him.

A few years ago there was a huge ice storm where I lived and the power was out for thousands of us. We went five days without power and some went two weeks.

Stores were closed or did have fresh food, most couldn’t cook, restaurants were not an option either.

You learn how to get through things like that when faced with adversity and the reality that nothing can be done until the power situation got fixed.

Raniere, on the other hand, appears to have a strong sense of entitlement to be comfortable. He’s used to being waited on by his girl servants, enjoyed the comforts of being the King of NXIVM and the mastermind behind a criminal organization.

He finally got caught with his hand in the cookie jar and put himself in this situation.

He will use every excuse to have some freedom. A glimmer of hope to leave the country once again but this time not be found by the Feds.

Let’s hope the Judge sees through this silly game of “poor me” suffering and keeps Raniere right where he belongs, the MDC